1 Site Visit Report Alaska Seafood Processing Industry Petition Response

Lindsay Guzzo Environmental Engineer U.S. Environmental Protection Agency Region 10 Permits Division guzzo.lindsay@epa.gov

206-553-0268 Betsy Bicknell Senior Environmental Engineer Eastern Research Group, Inc. (ERG) betsy.bicknell@erg.com

703-633-1612

Plant Name Trident Seafoods

Plant Address Kodiak, Alaska

NPDES Permit # AKG528833

Date of Visit Tuesday, August 17, 2010 People Contacted Greg Hathaway, Plant Manager Roger Wagner, Assistant Plant Manager Jim Ewing, Corporate Quality

Assurance

Seafood processed Pollock Other groundfish (halibut, cod, rockfish, flatfish)

Crab

Salmon

Products Fresh and frozen: Whole fish (H&G)

Fillets

Surimi

Crab Range of annual production vol ume 50 to 60 million pounds/year Months of operation Year round, 250 to 350 days per year Discharge type Screened solids are trucked to Kodiak Fishmeal Company Screened wastewater is discharged through NPDES permitted outfall, meets O&G and TSS limits. Website http://www.tridentseafoods.com/

Trident’s Kodiak plant is built in and around the grounded vessel Star of Kodiak , the former liberty ship Albert M. Boe (Figures 1 and 2), which was brought to Kodiak to replace the plant that was completely destroyed by the 1964 tsunami.

At the Kodiak plant, Trident processes re latively little salmon. Pollock is the major product and they process other groundfish, in cluding halibut, cod, ro ckfish, and various flatfish. They also process some crab. They haven’t processed he rring in 10 years, but may get some in 2011. They do not process shrimp.

Trident Kodiak produces fresh and frozen pr oducts, in the form of headed and gutted (H&G) fish and fillets. They also make suri mi from pollock. Trident managers estimated they use 1 MGD of city water.

Operations. Fish are pumped off the fishing boats ( Figure 3 ) and stored in refrigerated seawater (RSW) tanks ( Figure 4 ) or pumped directly into the plant. Trident may also2 unload fish using a brailer (an unloading a pparatus with a rigid frame from which is suspended a net bag with a drawstring and tr ip device). Fish are added to the top and released through the bottom. Tanks hold 850,000 pounds and each boat’s catch is stored separately. Boats bring crab in totes which are unloaded from the boat and tipped into the plant’s crab hopper.

Each boat’s catch is sorted by species to veri fy that only fish for which the fisherman has a valid permit (i.e., fish that he can legally catch) are processed for human consumption. Figure 5 shows the conveyer system for sorting fish. Fish that are removed from the

catch are sent to the Kodiak Fishmeal Company and include out-of-season species,

undersized fish that can’t be made into surimi, squid, jellyfish, and smelt. The temperature and weight of the legal catch is recorded and the fish are transferred to the processing plant. Figure 6 shows the flume chute that sends the fish into the processing

center.

Trident operates separate lines for cod, flat fish, and rockfish. These fish are headed, gutted, cleaned, and trimmed. Guts and trimmings are dropped into a tote or sluiced to

floor drains that lead to a large sump in the basement. Figure 7 shows an overview of the processing floor.

Roe from several species are separated from the guts and sold as separate products. In addition to salmon roe, which is sold in the U.S. and Europe, pollock roe, which is orange, is sold in Japan. Cod roe is graded by color and sold to Korea. Frozen cod heads are also shipped to Korea.

In addition to the fish lines, Trident also operates a surimi line and processes live crabs.

Crabs are cooked and shelled. Waste shell is separated from other wastes and totes of

crab shells are trucked to the K odiak Fishmeal Company plant.

Surimi. Trident Kodiak makes two grades of surimi:

 Top grade, made from fillets; and

 Second grade, made from the flesh removed from the frames.

Ground fish is passed through an Alfa-Laval two-phase decanter to separate solids (protein) from liquid. The solid s are minced in a screw pres s and then forced through the holes in a refiner. Skin and bones are separate d at this stage and discharged to waste.

The liquid waste from the surimi line can reach a BOD 5 concentration of 1,500 mg/L. During surimi production, Trident has sample s of its wastewater analyzed for BOD 5 by a third party laboratory (Kodiak Seafood Laboratories run by Chri s Sanitto, who is also the QA Manager for Western Seafoods). The suri mi line discharges about 300,000 gallons per day. Surimi is packed into 22 pound (10 kg) trays and frozen in the plate freezer Figure 8 shows a walk-in freezer while Figure 9 shows the rows of block freezers.

.

Shipping. Products are shipped from Kodiak by ai r or sea. A container ship leaves Kodiak twice a week, while a barge leaves once a month. Refrigerated vans of frozen3 seafood are transported by ship and barge. Fresh fillets are shipped by air freight on

Alaska Air.

Waste Management. Fish waste is sluiced to a pit sump in the basement

. Water and solids that accumulate in the sump are pumpe d to the roof level to an interior-feed rotating screen

. Figure 10 shows the interior of the screen and Figure 11 shows an

exterior view. The screen as a 1 mm mesh. The wastewater that flows through the screen is discharged through the plant’s NPDES perm itted outfall, 200 feet from shore. The wastewater is periodically sampled and an alyzed for TSS, O&G, and pH. Wastewater from surimi production is also analyzed for BOD 5 . The sampling port is shown in Figure

12

. Samples for O&G analysis are collected as grabs. Samples for the other analytes are collected as grab composites. Because permit limits are in pounds per day. Trident uses the metered incoming water flow and a cal culation methodology provi ded in the permit to calculate the mass of pollutant discharg ed. Trident also meters the wastewater discharge. Figure 13 shows the effluent discharge pipes.

According to the Trident managers, the rotary screen requires little maintenance. The bearing and drive train motor are inspected and lubricated annuall y. The screen is 20 years old and has lots of remaining life.

Solids screened from the wastewater flow ar e discharged from the end of the rotating screen into a hopper two levels below the screen ( Figure 14 ). Trident hires a trucks to pick up waste and haul it to the Kodiak Fish meal plant. The trucks are loaded directly from the hoppers. They come as often as needed to remove the waste solids, which may be every three hours when the plant is busy. The trucks ar e inspected by the state and DOT. The truck loading area and truck are cove red to keep eagles and other birds from getting into the waste. When asked if ci tizens had any complaint about odor from the trucks, the Trident managers said no, but ther e have been complaints about the odor from the fishmeal plant.

Compliance Concerns. Ms. Guzzo asked if Trident had any problems meeting their discharge limits or other compliance concerns . Jim Ewing mentioned that they had found inconsistency between laborat ories analyzing samples for O&G. One lab measured high

concentrations and the other measur ed no detectable concentration.

Trident managers reported no problems comp lying with their discharge permit limits.4 Figure 1. Stern, Star of Kodiak

Figure 2. Star of Kodiak (former liberty ship SS Albert M Boe)5 Figure 3. Fish pump hose

Figure 4. Fish holding tank6 Figure 5. Fish conveyor7 Figure 6. Flume

Figure 7. Overview8 Figure 8. Freezer9 Figure 9. Block freezers10 Figure 10. Rotary screen11 Figure 11. Rotary screen exterior12 Figure 12. Sampling point13 Figure 13. Effluent14 Figure 14. Truck loading hopper